Regulating Emerging Tech – Introduction of M2M Communication Authorization under the Unified License Framework

(a)  

Access and integration: This service allows (i) access to resources and (ii) integration of resources.

(b)             

Support and control of M2M / ‘Internet of Things’ (‘IoT’) capable infrastructure: M2M communication forms a part of IoT. M2M communication works in combination with big data analytics, cloud computing, and sensors and actuators to run smart devices, e.g., enabling consumers to control devices at their home from virtually anywhere.

(c)  

Offering of M2M/IoT capabilities: Entities can offer services relating to provision of network capabilities and resource exposure.

(d)             

Provision of services through ‘LPWAN’: The entities that intend to provide services exclusively through the LPWAN (which is a type of ‘Wide Area Network’ which provides wireless connectivity to low-power devices over a large distance), or equivalent technologies using unlicensed spectrum will be required to obtain the New Authorization.

(e) 

Provision of services through radio access: Entities can provide M2M services through radio access as well.

§   

Service area: The New Authorisation is granted for three different categories; generally, for operating at a national level, state level, or district level.

§   

Acquisition of customers: Entities can acquire customers to deliver the services offered through its network using the technology deployed by it.

§   

‘Quality of Service’ (QoS) requirements: The New Authorization prescribes a ‘duty cycle’ of 10%, both at the device level and network level for M2M devices and services. ‘Duty cycle’ is a QoS standard.

§   

Adherence with ‘Know Your Customer’ (KYC) norms: Entities are required to adhere to KYC and related guidelines issued by DoT. The DoT issued a notification in 2018 providing instructions for fulfilment of KYC norms by entities providing M2M communication services and also for implementing restrictive features (calls, SMS and data communication on a limited basis) for SIMs to be used in M2M communication.

§   

Maintenance of records: Entities are required to maintain records relating to details of all the customers of M2M services, and also maintain updated records regarding (a) details of M2M devices, including make, model, registration number, etc. of the M2M devices, and (b) corresponding name and address of custodian of M2M devices. This information is required to be made available to the DoT, and any changes in customers and M2M devices details are required be updated.

§   

Interconnection: Entities are allowed to interconnect with the network of other licensees holding the New Authorization; and entities operating through LPWAN are permitted to obtain bandwidth from licensed service providers to transport backend traffic to the cloud or servers.

§   

Security conditions: The New Authorisation also provides a host of security conditions, including (a) maintaining log-in/log-out details including IP detail records of all subscribers for services provided for the prescribed time period; and (b) making copies of all the packets originating from / terminating into the M2M devices/equipment available to the DoT/security agencies for interception and monitoring. It is unclear whether this is information is to be made available on a periodic basis, or as may be required by the DoT/security agencies.